ENVIRONMENTAL MANAGEMENT MANUAL

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1 TUBOS REUNIDOS INDUSTRIAL S.L.U. ENVIRONMENTAL MANAGEMENT MANUAL TUBOS REUNIDOS INDUSTRIAL S.L.U. Bº Sagarribai, Amurrio, Alava. www. tubosreunidos.com

2 Revision Date Modified section Description of modification Launch of ENVIRONMENTAL MANAGEMENT MANUAL M.M.000 / M.M.100 Revision of Environmental Policy. New P.M All Update. Change of name of the company Controlled paper copy Nº: Uncontrolled paper copy Carried out by: Checked by: Approved by: Name: N. del Olmo C. San Martín E. Arriola Date: Signed: Edition 2 (September 12th 2012) Page 2 of 11

3 INDEX M.M. 000: INTRODUCTION... 4 a) Company Activity of TUBOS REUNIDOS INDUSTRIAL S.L.U.:... 4 b) Environmental Policy:... 4 c) Structure of the Environmental Management System documentation... 5 M.M. 100: ENVIRONMENTAL PLANNING... 5 A) Description... 5 a) Definition of functions and responsibilities... 5 b) Identification of significant environmental aspects... 5 c) Identification of legal and other requirements... 6 d) Objectives, targets and environmental management programmes... 6 e) Training, awareness and professional competence... 6 f) Environmental Communication... 6 g) Environmental Management System Documentation... 7 B) Procedures... 7 M.M. 200: ENVIRONMENTAL IMPLementation... 8 A) Description... 8 a) Operational control... 8 b) Maintenance of equipment and installations... 8 c) Emergency Plan... 8 d) Environmental requirements to suppliers and contractors... 8 Procedure... 9 M.M. 300: ENVIRONMENTAL checking... 9 Description... 9 a) Monitoring and measurement... 9 b) Audit c) Management Review B) Procedures M.M. 400: ENVIRONMENTAL CORRECTION AND IMPROVEMENT Description a) Identification and processing of Non-conformity, Corrective and preventive action B) Procedures Edition 2 (September 12th 2012) Page 3 of 11

4 M.M. 000: INTRODUCTION This Manual explains the aspects of the Environmental Management System of TUBOS REUNIDOS INDUSTRIAL S.L.U. in accordance with the requirements of the UNE-EN ISO14001 standard in its current revision. The purpose of this Manual is to establish the policy and general criteria of the Environmental Management System of TUBOS REUNIDOS INDUSTRIAL S.L.U., through the definition of the activities that must be carried out and responsibilities. It applies to all activities of TUBOS REUNIDOS INDUSTRIAL S.L.U. with potential impact on the environment. a) Company Activity of TUBOS REUNIDOS INDUSTRIAL S.L.U.: TUBOS REUNIDOS INDUSTRIAL S.L.U. has three production units involving the following activities: Steelworks Unit: production of carbon-and alloy steels in round profiles (160, 200 and 238 mm) and square profiles (140 to 210 mm) Tubes Unit: production of hot rolled seamless carbon and alloy steel tubes (outside diameter between 26.7 mm and mm and wall thickness between 2.5 mm and 20 mm). Cold Drawn Unit: production of cold drawn seamless carbon and alloy steel tubes (outside diameter between 14.0 and mm and wall thickness between 1.0 and 20.0 mm. b) Environmental Policy: TUBOS REUNIDOS INDUSTRIAL S.L.U. is committed to undertake its activities in such a way that respects the ENVIRONMENT taking into account the basic principles established in the Environmental Policy, motor for the implementation and continual improvement of the Environmental Management System in all the activities carried out. The Environmental Policy is is available to the public. It is periodically reviewed for its adaptation to the changing environmental circumstances. Edition 2 (September 12th 2012) Page 4 of 11

5 c) Structure of the Environmental Management System documentation M.M. 100: ENVIRONMENTAL PLANNING A) Description a) Definition of functions and responsibilities Top Management of TUBOS REUNIDOS INDUSTRIAL S.L.U. has appointed the Technology Area Director Department as its representative in all relating to the environmental management of the company, taking on the role and responsibility of Environment Director. For each of the other roles related to environmental management, the responsibilities have been documented. b) Identification of significant environmental aspects TUBOS REUNIDOS INDUSTRIAL S.L.U. A. identifies the parts of those phases or stages of its activities which may affect the environment and those that it can influence. This identification of the environmental aspects is carried out for the various environmental areas established in TUBOS REUNIDOS INDUSTRIAL S.L.U. and is periodically reviewed. Those aspects which may have significant impact on the environment are determined by the criteria of significance laid down in accordance with the Environmental Policy. Edition 2 (September 12th 2012) Page 5 of 11

6 c) Identification of legal and other requirements TUBOS REUNIDOS INDUSTRIAL S.L.U. has the necessary services and resources to ensure that it has identified and has access to the applicable legal requirements and other requirements to which the organisation subscribes and keep them up to date. Said requirements are also identified when undertaking new projects and works. d) Objectives, targets and environmental management programmes Top management of TUBOS REUNIDOS INDUSTRIAL S.L.U. lays down its Environment Plan annually. This basically comprises the environmental objectives, which are established according to the Environmental Policy and the conclusions of the Management review. In order to ensure that the proposed objectives are undertaken, these are specified as environmental targets and their implementation, roadmap and those responsible are stipulated in the Environmental Plan. The Environmental Plan includes the chapters of the Investment Plan and Training Plan referring to environmental aspects. e) Training, awareness and professional competence As part of the annual Training Plan of TUBOS REUNIDOS INDUSTRIAL S.L.U., a study of the training and awareness needs is carried out for each of the areas. This is in order to ensure that all the employees are aware of their roles and responsibilities in achieving conformity with the requirements of the Environmental Management System and are also aware of the impacts associated with their work on the environment. In order to ensure the competence of employees, the requirements for professional competence are stipulated for those employees carrying out specialised environmental management roles or those that can have significant environmental impact associated with their work. f) Environmental Communication TUBOS REUNIDOS INDUSTRIAL S.L.U. has laid down the responsibilities and ways of communication for any communication relating to environmental management. Downstream internal communication comes from the Management or the Environment Department, via the various committees, circulars, notice boards etc. To channel internal communication from employees in general to the Environment Department there are other tools such as Non-conformity Reports, Health and Safety Committee, etc. As far as communications from interested parties are concerned, these are sent to Environment Manager who decides who should reply. Edition 2 (September 12th 2012) Page 6 of 11

7 g) Environmental Management System Documentation The Environmental Management Manual and the Environmental Policy of TUBOS REUNIDOS INDUSTRIAL S.L.U. are approved by the General Manager. The procedures and instructions of the Environmental Management System are drafted, updated and distributed by the Environment Department once they have been approved by the Technology Area Director. The records belonging to the Environmental Management System, as well as who is responsible for their filing and maintenance, are specified in the procedures and instructions. B) Procedures Ref. P.M.101 P.M.102 P.M.103 P.M.104 P.M.105 P.M.106 P.M.107 P.M.108 P.M.109 P.M.110 Title DEFINITION OF FUNCTIONS AND RESPONSIBILITIES IDENTIFICATION OF SIGNIFICANT ENVIRONMENTAL ASPECTS IDENTIFICATION OF LEGAL REQUIREMENTS AND OTHERS ANNUAL ENVIRONMENT PLAN TRAINING, AWARENESS AND PROFESSIONAL COMPETENCE ENVIRONMENTAL COMMUNICATION STANDARDISATION AND DOCUMENTATION FORMAT CONTROL OF DOCUMENTS CONTROL OF RECORDS NEW PROJECTS AND WORKS Edition 2 (September 12th 2012) Page 7 of 11

8 M.M. 200: ENVIRONMENTAL IMPLEMENTATION A) Description a) Operational control The procedures and instructions of the Environmental Management System of TUBOS REUNIDOS INDUSTRIAL S.L.U. establish the responsibilities and control methods for those activities and operations which generate significant environmental aspects affecting the atmosphere, water, land or use of natural resources and raw materials. b) Maintenance of equipment and installations The Environmental Management System of TUBOS REUNIDOS INDUSTRIAL S.L.U. ensures, via the various tools and resources at its disposal, the correct functioning of the equipment and installations involved in the significant environmental aspects of the company, such as installations for dedusting, waste water treatment, storage of chemical products, etc. c) Emergency Plan The Emergency Plan of TUBOS REUNIDOS INDUSTRIAL S.L.U. lays down the actions to be taken, organisation and technical resources at its disposal to respond to those situations which are identified as potential accidents or emergency situations which may affect the environment. d) Environmental requirements to suppliers and contractors TUBOS REUNIDOS INDUSTRIAL S.L.U. establishes the environmental requirements for those suppliers which supply products that, once on the premises, may have an adverse impact on the environment. Moreover, TUBOS REUNIDOS INDUSTRIAL S.L.U. informs the contractors that carry out work on the premises of the environmental requirements, procedures and instructions of the Environmental Management System that they must apply. The contractors employees carrying out work which may have significant environmental impacts must also prove that they comply with the requirements for professional competence laid down by TUBOS REUNIDOS INDUSTRIAL S.L.U. Edition 2 (September 12th 2012) Page 8 of 11

9 Procedures Ref. P.M.201 P.M.202 P.M.203 P.M.204 P.M.205 P.M.206 P.M.207 P.M.208 P.M.209 Title WASTE MANAGEMENT WATER MANAGEMENT AIR EMISSIONS MANAGEMENT ENERGY MANAGEMENT MANAGEMENT OF NUISANCE TO SURROUNDING AREA MATERIALS MANAGEMENT MAINTENANCE OF EQUIPMENT AND INSTALLATIONS ENVIRONMENTAL EMERGENCY PLAN COMMUNICATION OF ENVIRONMENTAL REQUIREMENTS TO SUPPLIERS AND CONTRACTORS M.M. 300: ENVIRONMENTAL CHECKING A) Description a) Monitoring and measurement TUBOS REUNIDOS INDUSTRIAL S.L.U. chooses the indicators that allow it to monitor and measure the key characteristics of the activity and operations which might have significant environmental impacts. For each of these factors a responsible of the monitoring and measurement, the method of monitoring, the approval criteria and the way it is recorded are established. Any deviation from these indicators will be considered to be a Nonconformity. The inspection, monitoring and measurement equipment used to monitor and measure the significant environmental aspects are included in the Calibration System of TUBOS REUNIDOS INDUSTRIAL S.L.U. to ensure the identification, maintenance and record of the calibration. Evaluation of compliance with legal requirements and other requirements to which the organisation subscribes is undertaken at least once a year, based on the identified legal requirements, the results obtained in the audit, the indicators of environmental performance, etc. Edition 2 (September 12th 2012) Page 9 of 11

10 b) Audit All the areas and departments that carry out activities related to the Environmental Management System of TUBOS REUNIDOS INDUSTRIAL S.L.U. are audited at least once a year as stipulated in the Annual Audit Plan. The audit verifies whether the system has been correctly implemented and whether it complies with the requirements laid down in the Plan and in the current revision of the ISO regulation. The results of the audit are documented in a detailed report which is distributed to the Management and included in the information taken into account in the Management Review. c) Management Review The monitoring of the Environmental Management System is ensured via the periodical meetings of the various company committees in which the Environment Department takes part: Management Committee, Industrial Committee and Health and Safety Committee. Annually, the Quality and Environment Committee, presided by the General Manager, carries out the Environment System Management Review based on the information provided by the Environment Department (fulfilment of objectives and targets, audit results, corrective and preventive action, concerns expressed by the interested parties, etc.). The Quality and Environment Committee evaluates any environmental improvement made, the Environmental Management System review and any eventual need to change the policy, objectives or any other part of the system. The conclusions of this review are taken into account when establishing the new Annual Environmental Plan. B) Procedures Ref. P.M.301 P.M.302 P.M.303 P.M.304 P.M.305 Title MONITORING AND MEASUREMENT OF ENVIRONMENTAL PERFORMANCE EVALUATION OF LEGAL COMPLIANCE CALIBRATION OF INSPECTION, MEASUREMENT AND TESTING EQUIPMENT AUDIT MANAGEMENT REVIEW Edition 2 (September 12th 2012) Page 10 of 11

11 M.M. 400: ENVIRONMENTAL CORRECTION AND IMPROVEMENT A) Description a) Identification and processing of Non-conformity, Corrective and preventive action All the employees of TUBOS REUNIDOS INDUSTRIAL S.L.U. and the contractors are obliged to inform the Environment Head of the area immediately of any non-conformity that may occur. The Environment Department, using the various sources of information on the compliance with the environmental requirements (internal audits, identification of non-conformity, analysis of environmental accidents etc.) chooses the actual problems and opportunities for improvement to establish the corrective and preventive action in order to avoid their recurrence. The head of the affected area investigates the causes of the non-conformity or potential risk situation. With the Environment Department, they propose the most suitable and viable corrective and preventive actions and establish the responsible and the roadmap for the corrective action. Once the action is implemented, the Environment Department evaluates the effectiveness of the action taken; the approval of the Environment Manager is necessary for its finalisation. B) Procedures Ref. P.M.401 Título NON-CONFORMITY, CORRECTIVE AND PREVENTIVE ACTION Edition 2 (September 12th 2012) Page 11 of 11

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